i)the dispersion modelling was undertaken using breeze aermod (breeze version 7.0.58 and aermod...

WYG Environment..........................part of the WYG~

26'" November 2010

...........................I)The 11

_, ~~C iC\OSonja SmithOffice of Climate, Licensing and Resource UseEPA Regional InspectorateInniscarraCounty Cork.Ireland

Dear Sonja,

Re: Quinn Cement IPPC Licence Response (P037S-02)

Further to your recent correspondence, please find enclosed 2No. hard copies CD copies of our response toyour comments in relation to the air dispersion modelling submitted in support of the IPPC licence applicationon behalf of Quinn cement.

I hope the above addresses each of the EPA's comment sufficiently, however if you require any furtherinformation please do not hesitate to contact me at your convenience.

Yours sincerelyfor WYG ENVIRONMENT

Rosalind Spainsenior Environmental Consultant

Matt HolfordRegional Director

creative minds safe hands........................... ...... .... . ......................Quay west at MediaOtyUK,. Trafford Wharf Road, Trafford Par1<. Mi7 IHHTel: +44 (0)161 an 3223 Fax: +44 (0)161 872 3193 Email: [email protected]

WYG EnvIronment P1annltlg Transport ltd Reglst:ered In Engl¥ld Number: 3050297

Registered otnce: Amdale Court, Otley Road, Headlngley, L56 2UJ

www.wyg.com

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Quay West at MediaCityUK, Trafford Wharf Road, Trafford Park, M17 1HH Tel: +44 (0)161 872 3223 Fax: +44 (0)161 872 3193 Email: [email protected] www.wyg.com

Reference: A044734-rs-bm-251110-L2098 25th November 2010 Brian Meaney Environmental Protection Agency Headquarters PO Box 3000 Johnstown Castle Estate County Wexford Ireland Dear Brian, Re: Quinn Cement IPPC Licence Response (PO378-02) Further to your recent correspondence, please find enclosed our response to your comments in relation to the air dispersion modelling submitted in support of the IPPC licence application on behalf of Quinn cement. Letter dated: 17th September 2010 Explain the elevated levels of hydrogen fluoride in the ambient monitoring program, with particular regard to the potential for existing emissions from the installation to be the source of the levels identified. Stack gas emission monitoring may be required. In the assessment of ambient levels of hydrogen fluorides, the licensee should consider other (EI) national standards, e.g. German TA-Luft Regulations, and international standards, e.g. the WHO Air Quality Guidelines. Consultation with the production team has indicated nothing unusual with the Plant operations during the monitoring campaign. Monitoring of hydrogen fluoride (HF) at stack is not undertaken at the installation therefore this cannot be analysed. Further analysis of the monitoring report and consultation with Environmental Efficiency has been undertaken to clarify the results. The laboratory analysis sheets have been provided for the period in question. On inspection the Limit of Detection (LoD) has been incorrectly reported in the monitoring as µg.m-3 when the analysis sheet states µg.F. Gradko were consulted to obtain the LoD in µg.m-3 this was calculated and stated as 2.09µg.m-3. This changes the range in the HF monitoring and also the background concentrations that were used in the dispersion modelling. In light of this an Addendum to Application Attachment I.1 has been provided. The following annual mean EALs for HF are available from other national standards: TA-Luft – 0.4µg.m-3 UK Environment Agency – 16µg.m-3

(based on the conversion of the 8-hour reference period converted to annual mean from Environmental Permitting H1 Environmental Risk Assessment Annex (f) Air Emissions)

It should be noted that the LoD for the diffusion tubes is 2.09µg.m-3 which is greater than the TA-Luft EAL. Comparison with the TA-Luft is not appropriate therefore the results have been compared against the UK Environment Agency EAL, details of which are contained within the Addendum. Carry out a revised air dispersion model in line with the Agency’s Guidance note Air Dispersion Modelling from industrial Installations Guidance Notes (AG4), available on the Agency’s website. This should address

WYG Environment

part of the WYG group

.........................................

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• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •

WYG Environment Planning Transport Ltd Registered in England Number: 3050297

Registered office: Arndale Court, Otley Road, Headingley, LS6 2UJ

WYG Environment•••••••••••••••••••••••••••••••••••••••••

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WYG Envin::«nent P\aooiOQT~ Ud Registered III England N.IIl'Iber: 3050297

RegiStered office: ArIlGaIe CCut, Otley Ri:»ll, Heaclirlglev, LS6 2UJ

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the impact of PM2.5 levels and the relevant standard from Directive 2008/50/EC should be used in this regard. In the presentation of the results, the grid reference of the location of maximum impact and the relevant concentration level should be provided. The contour maps should be colour coded and graded for ease of reading. Where no EU air quality standards exist the licensee should considered the hierarchy of standards to be used, as outlined in Guidance Note AG4. In particular a more detailed risk assessment should be used for PCDDs and PCDFs in line with WHO and US EPA recommendations (i.e. tolerable daily intake approach). An assessment of PM2.5 has been undertaken assuming the entire particulate matter is emitted as PM2.5. Although this is a conservative approach, in lieu of any specific particulate matter analysis from the operation it is considered appropriate. The results of the model predictions at each discrete receptor, inclusive of background, are summarised below. Where modelling results exceed the relevant AQS, these are shown in bold text.

Receptor Predicted Annual Mean PM2.5 Concentration

(µg.m-3)

R1 8.68

R2 8.55

R3 8.44

R4 8.54

R5 8.46

R6 8.47

R7 8.45

R8 8.47

R9 8.40

R10 8.88

R11 8.67

R12 9.57

R13 9.00

As indicated above, there were no predicted exceedences of the annual mean AQS for PM2.5 at any discrete receptor location. A review of the plotfile contained within Figure 1 indicated that there were no predicted exceedences of the AQO for PM2.5 throughout the entire modelling area. Each of the plot files presented within Application Attachment I.1 have been colour coded for ease of reading as requested. The location of the maximum predicted pollutant concentration has also been included. These are provided and are numbered as within the Application Attachment I.1 for comparison purposes. For those pollutants identified as not having a specific air quality standard further analysis has been undertaken comparing results to other EU member states statutory standards. These are detailed below.

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Maximum Predicted

Concentration (µg.m-3)

Pollutant Limit Type Value Guideline Source

Process Contribution

(PC)

Predicted Environmental Concentration (PEC) (PC +

Bg) 50µg.m-3 99%ile PC Danish EPA 7.81(1) 16.69(1)

HCl 1-hour 750µg.m-3 PEC UK EA 7.81 16.69

20µg.m-3 99%ile of PC Danish EPA 0.79(1) 3.63(1)

1-hour 160µg.m-3

PEC UK EA 0.79 3.63

0.4µg.m-3 as PEC

or 0.04µg.m-3 as PC TA-Luft 0.01 1.43

HF

Annual Mean 16µg.m-3 PEC UK EA 0.01 1.43

NOTES: (1) The value presented is the maximum 1-hour mean. If compliance is demonstrated as a maximum the 99%ile objective will also be achieved.

As shown above the limit values alter considerably between EU member states. The annual mean HF TA-Luft objective is not met as a total PEC, however it should be noted that the maximum PC is not exceeded. In this instance the exceedence of the TA-Luft is demonstrated as a baseline condition and not attributed to the installation. All other EU member state limit values are met. A detailed Human Health Risk Assessment for PCDD’s and PCDF’s will be provided as a standalone assessment. In addition to the above please also provide an updated non-technical summary to reflect the information provided in your reply. The information provided within this reply does not change any of the information provided within the Non-Technical Summary provided. It is therefore considered the Non-Technical Summary is still valid. Letter dated: 14th October 2010

1. Submit further details on the model: • Specify the model version used. The dispersion modelling was undertaken using Breeze AERMOD (Breeze version 7.0.58 and AERMOD executable 07026).

• Report the model accuracy and confirm is acceptable (see guidance notes). Breeze AERMOD has USEPA regulatory status and thus considered suitable to use in an assessment of this nature. • Confirm steady state assumptions apply and consider the potential for terrain downwash and plume

channelling (see guidance notes). AERMOD is a steady-state Gaussian plume model which can simulate dispersion from multiple sources. Complex terrain was simulated within the model using the AERMAP terrain pre-processer run with OS 1:50,000 scale digital height contour data at 10m vertical intervals. This is in accordance with the sector guidance note as terrain features are greater than 10% of the stack height within the modelling domain. Although AERMOD does not currently take upwind terrain features into account during modelling, it should be noted that terrain features do not differ by more than 40% of the GEP stack height within 800m of the site. It is therefore not considered that the wind field upwind of the stack will be subjected to additional turbulence and the use of AERMOD is appropriate.

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• Confirm recommended/default parameters for geophysical data were used. Justify any changes applied. The geophysical data was estimated from aerial photography and mapping of the area surrounding the met station. The data was then used to generate albedo, bowen ratio and roughness using the function within Breeze to derive boundary layer parameters such as Monin Obukov length, mixing height, stability class, turbulence etc.

• Confirm if urban or rural setting was used. The rural setting was used as less than 50% of the area within 3km of the source was either industrial, commercial or compact residential.

• Confirm the need or otherwise for deposition modelling for dust, metals, dioxins. During the consultation and scoping process deposition modelling was not specified as a requirement of the permit application and therefore it was not therefore undertaken as part of the application. A Human Health Risk Assessment will address the deposition of dioxins.

• Explain how all input parameters have been confirmed/justified. Input parameters were checked during the WYG’s quality control procedures.

2. Met station/met data: • Confirm ratio of mean wind speed at site of installation and at met station is between 0.9 and 1.1. This cannot be confirmed as there has been no site specific meteorological monitoring undertaken. It is considered that the use of 5-years of meteorological data from St Angelo meteorological station as recommended by ADM is suitable for this assessment. After consultation with the EPA it was proposed to use the wind climate maps available from Met Éireann to demonstrate that the mean wind speed at the installation and the meteorological station are similar. The wind Met Éireann wind map is displayed in Figure 2 with the location of St Angelo meteorological station and the proposed development also highlighted. As shown the 2No. sites are both within the 4-5m.s-1 contour. It is therefore considered that the met data used was suitable.

• Comment on the complexity of terrain and exposure of the met station as compared to that of site

installation. The met station is located at St Angelo meteorological station, located approximately 30km to the north of the Ballyconnell facility. The land surrounding the installation is open countryside with the small town of Ballyconnell to the south. The meteorological station is located at Eniskillen Airport approximately 20km north of Eniskillen. The terrain surrounding the station is similar to that of the installation although Lough Erne is located approximately 1.5km to the west. • Provide details of data capture and interpolation, and quantity (as %) of missing and calm hours.

Year Missing Data (%) Calm Hours (%)

2007 0.83 18.13

3. Carry out sensitivity analysis to include:

• Details of number of calm hours and confirmation if maximum concentrations occur during calm hours. In order to assess the time of the maximum pollutant concentration the wind conditions at the time of the 10 high NOx concentrations has been analysed.

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High Date Time Wind Speed

(m.s-1) Wind Direction

(degrees)

1 19 December 2007 18:00 1.5 59

2 19 December 2007 18:00 1.5 59

3 08 August 2007 21:00 1 67

4 08 August 2007 21:00 1 67

5 12 December 2007 18:00 5.1 151

6 19 December 2007 18:00 1.5 59

7 08 August 2007 21:00 1 67

8 01 May 2007 06:00 0.5 65

9 09 June 2007 22:00 0.5 68

10 18 December 2007 19:00 1.5 59

As shown above the top 10 predicted pollutant concentrations occur during low wind speeds when winds are from the WNW sector. The only exception is the 5th high concentration which occurred on 12th December with a wind speed of 5.1m.s-1 from the SE. It should be noted that the wind conditions are only considered ‘calm’ during the 8th and 9th high. It should be noted that the predicted high is based on the gridded receptor maximum, therefore the same day may have a number of concentrations within the ranking but these will at different locations. • Sensitivity analysis on building downwash (any buildings with width to height ratio outside range 0.3 to

3.0). The BPIP module was run within AERMOD which accounts for building downwash. All buildings within the site were represented in the model including those less than 40% of the effective stack height. Analysis of the building width to height ratio is detailed below.

Building Height X Y Radius Ratio W/H (min)

Ratio W/H (max)

Ballyconnell Facility

Cement Mill 31.70 31 34 1.55 1.70

Bagging Plant 15.00 9 24 0.17 0.44

Raw Mill 25.00 6 11 0.24 0.44

Workshop 10.00 21 22 1.40 1.47

Office Building 10.0 28 28 1.56 1.56

Waste Storage Bays 4.0 8 18 0.27 0.60

Additive Bins 20.00 10 21 0.19 0.40

Coal Storage 29.00 8 9

0.27 0.30

Cement Silo 1 57.00 10.45 0.37

Cement silo 2 57.00

10.45 0.37

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Building Height X Y Radius Ratio W/H (min)

Ratio W/H (max)

Cement silo 3 57.00 10.45 0.37

CF Silo 70.00 10.55 0.30

Clinker Shed 42.00 32.40 1.54

Gortmullen Facility

Pre-blending Shed 20.00 31 34 1.55 1.70

Raw Mill 54.00 9 24 0.17 0.44

Coal Miil 25.00 6 11 0.24 0.44

Coal Storage Bunker 15.00 21 22 1.40 1.47

Clinker Shed 18.00 28 28 1.56 1.56

Cement Mill 30.00 8 18 0.27 0.60

Cement Silos 52.00 10 21 0.19 0.40

Cement Bagging 30.00 8 9 0.27 0.30

DAF Store 20.00 24 28

1.20 1.40

It should be noted that the building width to height ratio is dependent upon the wind direction, therefore although a number of buildings do not demonstrate a ratio within the 0.3 – 3.0 range when considered in context of the wind direction modelled they may be. The model has been re-run without the BPIP module for the annual mean PM10 scenario. The results are presented below.

Annual Mean PM10 Concentration (µg.m-3)

Receptor With BPIP No BPIP Marginal Change

R1 10.41 10.28 -0.13

R2 10.21 10.16 -0.05

R3 10.07 10.04 -0.03

R4 10.19 10.14 -0.04

R5 10.08 10.06 -0.02

R6 10.10 10.07 -0.03

R7 10.08 10.05 -0.03

R8 10.10 10.07 -0.03

R9 10.02 10.00 -0.02

R10 10.68 10.48 -0.20

R11 10.38 10.27 -0.11

R12 11.31 11.17 -0.14

R13 10.62 10.60 -0.02

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As shown above running the model without the BPIP module generates lower results therefore the parameters using within the assessment are considered robust. • Sensitivity analysis on emission flow rate (maximum and normal). The maximum flow rate was used as a robust assessment in order to determine maximum ground level pollutant concentrations in accordance with best practice. In accordance with the guidance note analysis has been undertaken of the PM10 modelling using the 75% of the maximum flow rate. The flow rates used are displayed below.

Source Emission Limit

(mg.m-3)

Volumetric Flow Rate (stack conditions) (m3.s-1)

75% Flow Rate (m3.s-1)

Emission Rate (@75% Flow)

(g.s-1)

A2-01 30 166.67 125.00 3.7500

A2-02 50 106.56 79.92 3.9960

A2-03 50 16.67 12.50 0.6250

A2-04 50 19.44 14.58 0.7290

A2-05 50 83.33 62.50 3.1250

A13 30 8.17 6.13 0.1839

A14 40 4.67 3.50 0.1400

A15 40 27.80 20.85 0.8340

A16 40 50.00 37.50 1.5000

Analysis of the dispersion using the 75% flow rate, as recommended within the EPA guidance, is provided below.

Predicted Annual Mean PM10 Concentration (µg.m-3)

Receptor

Max Flow Rate 75% of Max Flow

Rate

% Change

R1 10.28 10.41 +1.26

R2 10.16 10.21 +0.49

R3 10.04 10.07 +0.30

R4 10.14 10.19 +0.49

R5 10.06 10.08 +0.20

R6 10.07 10.10 +0.30

R7 10.05 10.08 +0.30

R8 10.07 10.10 +0.30

R9 10.00 10.02 +0.20

R10 10.48 10.68 +1.91

R11 10.27 10.38 +1.07

R12 11.17 11.31 +1.25

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Predicted Annual Mean PM10 Concentration (µg.m-3)

Receptor

Max Flow Rate 75% of Max Flow

Rate

% Change

R13 10.60 10.62 +0.19

As shown above using a flow rate 75% of the maximum generates higher pollutant concentrations. It should be noted that these are within 2% of the predicted concentration using the maximum flow rate for all receptor locations and no receptors exceed the relevant air quality criteria.

4. Ambient monitoring program and background data used: • Comment on the influence of seasonal changes on ambient levels and potential impact on conclusions of

ambient monitoring program. Although it is noted that there are seasonal influences on ambient pollutant levels the scope of the monitoring was agreed with the EPA before commencement of monitoring. During winter months pollutant concentrations are usually elevated due to surface layer atmospheric inversions impairing effective dispersion. The opposite is true during the summer where dispersion is much more effective. The monitoring was undertaken during autumn which in theory has dispersion characteristics of both the summer and winter and when factored to annual mean concentrations. This trend is confirmed in monitoring from the UK AURN network which demonstrates that autumnal ambient pollutant levels are generally representative of annual means. • Confirm the background dioxin levels reported. Compare to levels reported in national and international

studies and explain any significant discrepancies. Monitoring of dioxins and furans was undertaken for 2No. 72 hour periods at monitoring location 7 using a single LVS3 sampler with PUF filter. On further analysis of the monitoring report the dioxins and furans concentration is stated as total concentration. In order to make a comparison with other monitoring studies the data needs to be converted using a Toxic Equivalent Factor (TEF) into a Toxic Equivalent Value (TEQ). The results are displayed below. Reference should be made to Table 1 and Table 2 at the end of this report for full details of the calculation.

Sample Period Total Dioxin and Furan Concentration (pg.m-3)

(reported)

Max. Total Dioxin and Furan Concentration (pgTEQ.m-3)

22/11/2008 – 24/11/2008 5.440 0.236

30/11/2008 – 01/12/2008 4.441 0.093

Average 4.941 0.165

As shown above converting the monitoring into TEQ has significantly altered the results. Monitoring as part of the DEFRA TOMPs network during 2008 shows annual average concentrations range between 1 – 24 fgTEQ.m-3 (0.001 – 0.0024 pgTEQ.m-3). This is considerably lower than those presented within the monitoring report. Further analysis has been undertaken on the monitoring to obtain the potential minimum TEQ possible, assuming all congeners were at the detection limit. The max in this case is 48 fgTEQ.m-3. On this assumption even if all congeners where below the limit of detection the results presented would be greater those within other monitoring campaigns.

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• Confirm the test method (diffusion tubes) for monitoring fluorides in ambient air is suitable. Confirm the detection limit, exposure period, type of diffusion tube and uncertainty in measurement. Confirm the device was validated.

The diffusion tubes are designed for ambient monitoring and comply with the requirements of EN13528. The method of baseline monitoring was accepted by the EPA on 04th June 2008. This correspondence is attached.

Detection limit 0.081µgF

Exposure period 2 weeks

Type of tube Gradko Fluoride diffusion tube complying to the requirements of EN13528 blank corrected

Uncertainty (Overall M.O.U 12.62+/-) 12.62 +/-

• Explain PM10 data for the second period of the monitoring program and explain why a quite different

background level was used in the model (9.86µg.m-3 from Defra mapping). The ambient monitoring of PM10 included a contribution of the existing installation and therefore is not considered to be a true background concentration. Using the monitoring data as background with the modelling would create a double counting of the contribution from the installation. Using non-background monitoring is not deemed to be good practice as it would significantly over estimate the impact of the proposed development. • Confirm that the location of monitoring for the second period conformed to requirements of the Air

Framework Directive (96/62/EC) for monitoring stations. The Air Framework Directive (96/62/EC) has been superseded by Directive 2008/50/EC which merged the previous legislation into a single directive, except for the Fourth Daughter Directive. In regard to monitoring stations the Air Framework Directive (96/62/EC) stated:

“Where pollutants have to be measured, the measurements shall be taken at fixed sites either continuously or by random sampling; the number of measurements shall be sufficiently large to enable the levels observed to be determined”

During the 1st period the analyser was located adjacent to the PFA Silo and may have been influenced by unloading and loading operations or overfilling of silos. The PM10 monitor was moved as far as possible away from on-site traffic and loading operations to enable analysis of the process emissions. It is considered that the monitoring during the second period conformed to the requirements of the Air Framework Directive (96/62/EC) and Directive (2008/50/EC). • Validate the model using the ambient PM10 data available (2

nd location/period). Refer to guidance notes. The PM10 dispersion model has been re-run for the period of monitoring. A graph displaying the monitoring results and the 24-hour predicted concentrations from the dispersion modelling are shown in Figure 3. As shown in Figure 3 the model performs well against the monitoring data. The trends are easily depicted especially the periods of elevated concentrations. The model is therefore considered appropriate in its application and results validated. • Validation analysis should look at data for wind blowing towards monitoring from stacks and when

blowing in the other direction. Analysis of the met data is displayed in Figure 4 for 2No. identified periods within the monitoring. These have been identified as:

• The period of exceedences between 11/11/2008 and 12/11/2008; and, • The period of low PM10 concentrations between 20/11/2008 and 25/11/2008.

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As shown in the frequency distribution charts and wind roses in Figure 4 during the period of elevated PM10 concentrations the majority of the winds were blowing from 170° to 280°. During these conditions the monitoring location was directly down-wind of the installation. During the period of low PM10 concentrations the wind were blowing from 260° to 310°, as shown on Figure 4. The monitoring location during this period was not directly down-wind of the installation. • Confirm if PM10 exceedences correlate with atmospheric stability and wind speed. For the same periods identified above, analysis of the wind speed and stability has also been undertaken. During the period of elevated monitored concentrations the wind speeds were much lower with a greater proportion of the period experiencing calm conditions. The alternative is true during the period of lower monitored PM10 concentrations with greater wind speeds aiding dispersion. • Identify other sources of PM10 emissions, e.g. stockpiles, and propose mitigation measures as necessary. Sources of fugitive dust emissions have been identified within Application Attachment E.1b. These include:

• Unloading and loading operations; • Transportation of materials between various unit operations; • Storage or raw material in external stockpiles; • Overfilling of storage silos; and, • Cyclone cleaning operations.

Where appropriate, measures to control fugitive dust emissions have been identified and will be implemented these include, but are not limited to, the use of integrated jet pulse filter close to filling devices and enclosed receiving stations. Full details of the measures to be implemented are found in Application Attachment E1.b.

5. Model HF for 24 Hour Averaging period. This has been undertaken, the maximum predicted 24-hour concentration is 2.91µg.m-3 and the plot file is presented in Figure 5.

6. Identify Natura 2000 sites in modelling domain (Northern Ireland and Republic) and clarify the potential impact on them.

Natura 2000 sites have been identified using the European Environment Agency website. Directive 2008/50/EC states that conservation sites only need to be considered where they fall within a set distance of the activity:

• More than 20km away from agglomerations or more than 5km from other built-up areas, industrial installations or motorways or major roads within more than 50,000 vehicles per day.

Figure 6 identifies the Natura 2000 sites within the extended modelling domain. Although the Directive states sites only need be considered if more than 5km from an installation, all sites within the 5km zone have been included for completeness. The EU Daughter Directive outlines annual mean target values for NOx and SO2 for the protection of ecosystems. In accordance with this EU legislation the predicted NOx concentrations have been analysed against the annual mean target value of 30µg.m-3. The NOx output has been plotted including the predicted background and is presented within Figure 7. The location of the Natura 2000 sites has also been included. As shown in Figure 7 the NOx objective for the protection of ecosystems is met at all relevant locations. In accordance with the EU Daughter Directive the predicted SO2 concentrations have been analysed against the annual mean target value of 20µg.m-3. The SO2 output has been plotted including the predicted background and is presented within Figure 8. The location of the Natura 2000 sites has also been included. As shown in Figure 8 the SO2 objective for the protection of ecosystems is met at all relevant locations.

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7. Reporting and Model Output:

• Re-submit figures 1 and 2 of ambient air monitoring report (in A3 size, clearly identify stacks and monitoring locations)

Figures 1 and 2 of the ambient air monitoring report are attached.

• Submit the report in line with AG4 guidance note on air dispersion modelling. The guidance note AG4 was not published at the time of submission of this application. The dispersion modelling report was undertaken in accordance with the most appropriate guidance at the time. It is considered that the report in addition to the comments addressed within this letter should sufficiently meet the requirements of the EPA. I hope the above addresses each of the EPA’s comment sufficiently, however if you require any further information please do not hesitate to contact me at your convenience. Yours sincerely for WYG ENVIRONMENT

Rosalind Spain Matt Holford Senior Environmental Consultant Regional Director

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25

321000 18

I

320500 ~16I

320000 14

319500 r10319000

8318500

322500

318000

321500

322000

225500 226000 226500 227000 227500 228000 228500 229000 229500 230000

Max =20.01Ilg.m-3 at 227555, 320223

Figure 1

Predicted Annual Mean PM2.5 Concentrations (lJg.m- 3 )

Dispersion Modelling Assessment on behalf of:

Quinn cement Ltd

Project Number: A044734/ 588

NGR: 225069,317807 to 230141, 322737

LEGEND

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Figure 2

Wind Map - Met Eireann


Quinn Cement Ltd

LEGEND

It should be noted that the locations are approximations.No further detailed mapping was available from Met Eireann

Project Number: A044734! 588

WYG Environment Planning Transport..........................part of the WYG group

•••••••••••••••••••••••••••

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90

80

70

60

50

40

30

20

10

Time series of Monitored and Modelled 25-hr PM10 Concentration

--Monitoring --Modelling

16

14

12

10

8

6

4

2

o

o -2

o 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 4041 42 43 44 45 46 47 48

Day

Figure 3

Time Series Plot of Monitoring and Modelled 24-hour PM10 Concentration

EPA Response of:

Quinn Cement Limited

LEGEND

Project Numller: A044734 I 588

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Period of Elevated PM10 Concentrations

N

Period of Low PM10 Concentrations

N

w I-t-+++-t--+-r-t-t-+-HE

s

11th November - 12th November 2008

Wind Speed(m/s)

8.80 (10.4%)

8.00 (6.3%)

7.00 (6.3%)

6.00 (10.4%)

5.00 (10.4%)

4.00 (27.1 %)

3.00 (8.3%)

2.00 (2.1%)

1.00 (2.1%)

0.00 (16.7%)

w 1--1-+-+--+--1--+-+-1 E

s

20th November - 25th November 2008

Wind Speed(m/s)

10.80 (21.5%)

8.00 (7.6%)

7.00 (11.1 %)

6.00 (11.1%)

5.00 (11.8%)

4.00 (16.0%)

3.00 (10.4%)

2.00 (2.8%)

1.00 (0.7%)

0.00 (6.9%)

Figure 4

Meteorological Data from St Angelo Meteorological Station

EPA Response of:

Quinn Cement Limited

LEGEND

Project Numller: A044734 I 588

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EPA Export 27-07-2013:00:16:09

3215002.94

321000

2.92

320500

2.9

320000

2.88

319500

2.86

319000

2.84318500

322500

318000

322000

225500 226000 226500 227000 227500 228000 228500 229000 229500 230000

Max = 3.63 Ilg.m-' at 2.2.5771,32.1449

Figure 5

Predicted 24-hour Mean HF Concentrations (lJg.m- 3 )


Quinn Cement Ltd


NGR: 225069, 317807 to 230141, 322737

LEGEND


•••••••••••••••••••••••••••

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325000

324000

323000

322000

321000

320000

319000

318000

317000

223000 224000 225000 226000 227000 228000 229000 230000 231000 232000

Figure 6

Natura 2000 Sites


Quinn Cement Ltd

LEGEND

Natura 2000 sites have been obtained from the European Agency website and are displayed in green.

Project Number: A044734! 588

NGR: 222753, 316612 to 232593, 325741


• • • • • • • • • • • • • • • • • • • • • • • • •••

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5

4

324000

20

323000

9

322000

8

321000'"7

3200006

317000

319000

318000

325000

223000 224000 225000 226000 227000 228000 229000 230000 231000 232000

Max = 8.80 IJg.m-3 at 226919, 321232

Figure 7

Predicted Annual Mean NOx Concentrations (lJg.m- 3 )


Quinn Cement Ltd


NGR: 222753, 316612 to 232593, 325741

LEGEND

It should be noted that the annual mean Air Quality Standard for NOx has beendesignated for the protection of eco-systems and not human health.


There are no predicted exceedences of the relevant AQO.


• ••••••••••••••••••••••••••

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32150020

321000

6

320500

5

320000

4

319500

3

319000

2318500

322500

318000

322000

225500 226000 226500 227000 227500 228000 228500 229000 229500 230000

Max = 4.99 IJg.m-3 at 226426,321740

Figure 8

Predicted Annual Mean S02 Concentrations (J.lg.m- 3 )

Dispersion Modelling Assessment on behalf of: Project Number: A044734/ 588

Quinn Cement Ltd NGR: 222753,316612 to 232593,325741

LEGEND

It should be noted that the annual mean Air Quality Standard for S02 has beendesignated for the protection of eco-systems and not human health.




• ••••••••••••••••••••••••••

32150020

321000

6

320500

5

320000

4

319500

3

319000

2318500

322000

322500

318000

225500 226000 226500 227000 227500 228000 228500 229000 229500 230000

Max =4.99 IJg.m-3 at 226426, 321740

Figure 8

Predicted Annual Mean S02 Concentrations (lJg.m- 3 )

Dispersion Modelling Assessment on behalf of: Project Number: A044734/ 588

Quinn Cement Ltd NGR: 222753, 316612 to 232593, 325741

LEGEND

It should be noted that the annual mean Air Quality Standard for S02 has beendesignated for the protection of eco-systems and not human health.



WYG Environment Planning Transport

part of the WYG group• ••••••••••••••••••••••••••

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EPA Export 27-07-2013:00:16:09

TABLE 1 Monitoring Period 1

Expressed as ng/sample

Congener Conc TEFs TEQ1 TEQ2 DL Rec % TEQ3

2378-TCDF 0.0079 0.1 0.0008 0.0008 0.0032 97 0.0003

12378-PCDF 0.0182 0.05 0.0009 0.0009 0.0032 91 0.0002

23478-PCDF 0.0193 0.5 0.0096 0.0096 0.0024 94 0.0012

123478-HxCDF 0.0219 0.1 0.0022 0.0022 0.0019 111 0.0002

123678-HxCDF 0.0248 0.1 0.0025 0.0025 0.0019 108 0.0002

234678-HxCDF 0.0312 0.1 0.0031 0.0031 0.0018 107 0.0002

123789-HxCDF 0.0058 0.1 0.0006 0.0006 0.0021 101 0.0002

1234678HpCDF 0.0869 0.01 0.0009 0.0009 0.0019 83 0.0000

1234789-HpCDF 0.0201 0.01 0.0002 0.0002 0.0027 68 0.0000

OCDF 0.2614 0.001 0.0003 0.0003 0.0035 0.0000

2378-TCDD - 1 0.0042 0 0.0042 89 0.0042

12378-PCDD 0.013 0.5 0.0065 0.0065 0.0049 87 0.0025

123478-HxCDD 0.017 0.1 0.0017 0.0017 0.0017 95 0.0002

123678-HxCDD 0.0214 0.1 0.0021 0.0021 0.0017 97 0.0002

123789-HxCDD 0.0233 0.1 0.0023 0.0023 0.0017 0.0002

1234678-HpCDD 0.0919 0.01 0.0009 0.0009 0.0025 70 0.0000

OCDD 0.2369 0.001 0.0002 0.0002 0.0048 48 0.0000

Total 0.901 0.039 0.035 0.010

Time (hr) 72

Flow Rate (m3.hr-1) 2.3

Volume (m3) 165.6

Concentration (ng.m-3) 0.005 0.000 0.000 0.000

Concentration (pg.m-3) 5.441 0.236 0.210 0.059

Concentration (fg.m-3) 5440.821 235.507 210.145 58.510

Sampling

* - Isomer Not Detected

TEQ - Toxic Equivalent Value

TEF - Toxic Equivalent Factor

Conc - Concentration

DL - Detection Value

TEQ1 - Concentration of Non Deteted Congeners at Detection Limit

TEQ2 - Concentration of Non Detected Congeners at Zero

TEQ3 - Concentration of Congeners at Detection Limit

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EPA Export 27-07-2013:00:16:09

TABLE 2 Monitoring Period 2

Expressed as ng/sample

Congener Conc TEFs TEQ1 TEQ2 DL Rec % TEQ3

2378-TCDF - 0.1 0.0002 0 0.0019 91 0.0002

12378-PCDF 0.0073 0.05 0.0004 0.0004 0.0016 85 0.0001

23478-PCDF 0.008 0.5 0.004 0.004 0.0012 85 0.0006

123478-HxCDF 0.0085 0.1 0.0008 0.0008 0.0031 106 0.0003

123678-HxCDF 0.0096 0.1 0.001 0.001 0.0032 102 0.0003

234678-HxCDF 0.0141 0.1 0.0014 0.0014 0.0031 99 0.0003

123789-HxCDF 0.0028 0.1 0.0003 0.0003 0.0039 96 0.0004

1234678HpCDF 0.232 0.01 0.0002 0.0002 0.0028 78 0.0000

1234789-HpCDF 0.0077 0.01 0.0001 0.0001 0.004 65 0.0000

OCDF 0.0476 0.001 0 0 0.0035 0.0000

2378-TCDD 0.0015 1 0.0015 0.0015 0.0036 78 0.0036

12378-PCDD 0.0058 0.2 0.0029 0.0029 0.0037 79 0.0007

123478-HxCDD 0.0065 0.1 0.0006 0.0006 0.0032 89 0.0003

123678-HxCDD 0.009 0.1 0.0009 0.0009 0.003 92 0.0003

123789-HxCDD 0.0069 0.1 0.0007 0.0007 0.003 0.0003

1234678-HpCDD 0.307 0.01 0.0003 0.0003 0.0044 64 0.0000

OCDD 0.0612 0.001 0.0001 0.0001 0.0044 42 0.0000

Total 0.736 0.015 0.015 0.008

Time (hr) 72

Flow Rate (m3.hr-1) 2.3

Volume (m3) 165.6

Concentration (ng.m-3) 0.004 0.000 0.000 0.000

Concentration (pg.m-3) 4.441 0.093 0.092 0.046

Concentration (fg.m-3) 4441.425 92.995 91.787 45.772

Sampling

* - Isomer Not Detected

TEQ - Toxic Equivalent Value

TEF - Toxic Equivalent Factor

Conc - Concentration

DL - Detection Value

TEQ1 - Concentration of Non Deteted Congeners at Detection Limit

TEQ2 - Concentration of Non Detected Congeners at Zero

TEQ3 - Concentration of Congeners at Detection Limit

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EPA Export 27-07-2013:00:16:09

2187(A division of Gradko International Ltd.)

st. Mattins House, 77 Wales Stt"ed Winchestet", Hampshire S023 ORRtel.: 01962860331 fax: 01962 841339 e-mail:[email protected]

LABORATORY ANALYSIS REPORTDETERMINATION OF ACID GASES IN DIFFUSION TUBES BY ION CHROMATOGRAPHY

REPORT NUMBER

BOOKING IN REFERENCE No

CUSTOMER

DATE SAMPLES RECEIVED

GRADKO LAB REF

30292

B 5545

Environmental EfficiencyConsultants LimitedIreland

11/09/2008

GIC 6264-6270

FLUORIDE AS HFTube Identification Date On Date Off Exposure J.l9F J.lgF -

(hrs) Total Blank J.lg/m3* ppb*1064

1 336 0.22 0.18 4.65 5.212 336 0.21 0.17 4.43 4.963 336 0.18 0.14 3.53 3.954 336 0.19 0.15 3.77 4.225 336 0.14 0.10 2.63 2.956 336 0.23 0.19 4.86 5.447 336 0.16 0.12 2.98 3.34

Lab Blank 0.04(RESULTS ARE BLANK CORRECTED)

OVERALL M.O.U.

ANALYST SIGNATURE

DATE OF ANALYSIS

12.62 +/

Analysed on Dionex ICS 3000

23/09/2008

LIMIT OF DETECTION

ANALYST NAME

DATE OF REPORT

0.081J.l9F

J. Farbiszewska

25/09/2008

THIS ANALYSIS HAS BEEN CARRIED OUT ON ACCORDANCE WITH IN-HOUSE METHOD GLM3

The Diffusion Tubes have been tested within the scoJle of Gradko International Ltd. Laboratory Quality Procedures calculations and assessmentsimrolving the exposure procedures and pel'iods provided by the client are not within the scope of our UKAS accreditation. Those results obtainedusing exposure data shall be indicated by an asterisk. Any queries concerning the data in this report should be directed to the Laboratory ManagerGradko International Ltd.Form LQF32 Issue 2 Page 1 of 2

~PORTOFFICIALLYCm~Dko International Ltd

This signatur c n ms the thenticity of this document

Signed............... .~ .tu chbury, Laboratory Manager

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EPA Export 27-07-2013:00:16:09

IPPC Licence Application Attachment I.1 Addendum

WYG Environment part of the WYG Group 1 creative minds safe hands

www.wyg.com

Quinn Cement Ltd

IPPC Licence Application

ADDENDUM TO ATTACHMENT No I.1DETAILED DISPERSION MODELLING

.. .. . ... ....

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Diffusion Tube Monitoring

1.1 Table 1 summarises the passive HF diffusion tube monitoring results.

Table 1 Summary of Passive HF Sampling Results

HF Concentration (µg.m-3) Monitoring Location

25/08/08 08/09/08 22/09/08 06/10/08 11/11/08 Average

1 5.00 <2.09 <2.09 <2.09 - 2.82

2 4.00 <2.09 <2.09 1.00 - 2.30

3 4.00 <2.09 <2.09 - <2.09 2.57

4 4.00 <2.09 <2.09 - 1.00 2.30

5 3.00 <2.09 <2.09 1.00 - 2.05

6 9.00 <2.09 <2.09 - - 4.39

2.74

NOTE: (-) Result not provided in monitoring report.

1.2 Although the EPA have not prescribed an EAL for HF comparison has been made with the UK

Environment Agency limit of 16µg.m-3. As indicated within Table 1, HF concentrations

measured during the passive diffusion tube survey were below the relevant EAL.

Background Concentrations used in Dispersion Modelling Assessment

1.3 Background concentration for HF has been determined from the average of all the monitoring

results. These have been used to provide a worst-case background value as monitored

concentrations include a contribution from the installation. A background concentration of

2.74µg.m-3 has been used for the purpose of this addendum.

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Results

1.4 The results of the model predictions for ground level HF concentrations at each discrete

receptor are summarised in Table 2.

Table 2 Summary of Predicted HF Concentrations

Receptor Predicted Annual Mean Concentration (µg.m-3)

Predicted 24-hour Concentration (µg.m-3)

Predicted 1-hour Concentration (µg.m-3)

R1 2.7405 5.4928 5.5260

R2 2.7405 5.4921 5.5243

R3 2.7405 5.4929 5.5303

R4 2.7405 5.4961 5.5265

R5 2.7405 5.4951 5.5281

R6 2.7405 5.4901 5.5322

R7 2.7405 5.4907 5.5328

R8 2.7405 5.4898 5.5329

R9 2.7404 5.4925 5.5341

R10 2.7405 5.4950 5.5266

R11 2.7405 5.4930 5.5261

R12 2.7407 5.4873 5.5304

R13 2.7412 5.4934 5.5725

NOTE: Inclusive of a background concentration of 2.74µg.m-3. Background concentrations for short term averaging period is double that of the annual in accordance with DEFRA guidance.

1.5 As shown in Table 2 the UK Environment Agency AQS is not exceeded at any assessment

location.

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i)the dispersion modelling was undertaken using breeze aermod (breeze version 7.0.58 and aermod...

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